Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff
Comments
None.
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Table of Contents
Item 1C. Cybersecurity
As a technology and communications company that globally
transmits large amounts of information over our networks, we recognize the critical importance of maintaining the security and integrity
of information and systems under our control. We view cybersecurity risk as one of our principal enterprise-wide risks, subject to control
and monitoring at various levels of management throughout our Company. We dedicate resources commensurate with our risk profile and business
size to programs designed to identify, assess, manage, mitigate and respond to cybersecurity threats.
As described in Item 1A “Risk Factors,”
several features of our operations heighten our susceptibility to cyber-attacks, including (i) our material reliance on systems owned,
operated or controlled by unaffiliated third-party operators (including carriers and network partners), (ii) our processing and storage
of large amounts of sensitive customer data in our telecommunications and fintech operations, and (iii) the complexity of our multi-continent
network composed of legacy and acquired systems. Cyber-attacks on our systems may be initiated by a wide variety of intruders, including
employees, cyber-criminals, nation state actors and other advanced persistent threat actors, and may include attempts by outside parties
to gain access to sensitive data that is stored in or transmitted across our network. Cyber-attacks can take many forms, including computer
hackings, computer viruses, ransomware, worms or other destructive or disruptive software, denial of service attacks, or other malicious
activities.
We have implemented cybersecurity risk management
procedures, in accordance with our risk profile and business size. We rely on our information technology to operate our business. As
such, we have policies and processes designed to protect our information technology systems, some of which are managed by third parties,
and resolve issues in a timely manner in the event of a cybersecurity threat or incident.
We have designed our business applications to minimize
the impact that cybersecurity incidents could have on our business and have identified back-up systems where appropriate. We seek to
further mitigate cybersecurity risks through a combination of monitoring and detection activities, use of anti-malware applications,
employee training, quality audits and communication and reporting structures, among other processes. We have a trained group of people
to carry out the activities of monitoring and detection of cybersecurity threats and respond to any cybersecurity threats or incidents.
The Head of IT department is responsible for oversight of cybersecurity risks and addressing potential cybersecurity risks to business
programs, employees, clients, vendors and partners. The Head of IT Department reports to our Chief Executive Officer who reports to the
Audit Committee at the board-level, as appropriate.
As of December 31, 2025, the Company has not identified
any cybersecurity incidents that have materially affected, or are reasonably likely to materially affect, our business strategy, results
of operations, or financial condition.
The Company continues to monitor its systems and
third-party environments for potential threats and to evaluate and enhance our cybersecurity controls as our business evolves, including
following acquisitions and the expansion of fintech services.
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.